ML20148N115
| ML20148N115 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 06/17/1997 |
| From: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19317C433 | List: |
| References | |
| AW-97-1124, NUDOCS 9706260086 | |
| Download: ML20148N115 (9) | |
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i Westinghouse.
Energy Systems Ba 355 Electric Corporation PIMsbuyri Pennsylvania 15230-0355 AW-97-1124 June 17,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
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ATTENTION:
MR. T. R. QUAY APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE j
SUBJECT:
AP600 DESIGN CERTIFICATION: SURVEY OF OPERATING PLANT FUEL i
LEAKAGE FOR REVIEW RADWASTE SYSTEMS i
Dear Mr. Quay:
The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")
pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
I The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW-97-1124 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
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Accordingly, it is respectfully requested that the subject information which is proprietary to l
Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-97-1124 and should be addressed to the undersigned.
Very truly yours, f
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Brian A. McIntyre, Manager j
Advanced Plant Safety and Licensing jml cc:
Kevin Bohrer NRC OWFN - MS 12E20
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9706260086 970617 I
i PDr ADOCK 05200003 E
AW-97-1124 i
(1). I am Manager, Advanced Plant Safety And Licensing, in the Advanced Technology Business
.. Area, of the Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.
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l (2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the~
Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
4 (3)
I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit in designating information as a trade secret, privileged or as confidential commercial or financial infennation.
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_(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's I
regulations, the following is furnished for consideration by the Commission in determining
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whether the information sought to be withheld from public disclosure should be withheld.
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(i)
The information sought to be withheld from public disclosure is owned and has been j-held in confidence by Westinghouse, j
j (ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for detennining-the types of information customarily held in confidence by it and, in that connection, i
utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existNg or potential 4
competitive advantage, as follows:
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AW-97 1124 (a)
The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
-i (b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved I
marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
1 (d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
i (f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
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(b)
It is information which is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services inv61ving the use of the itformation.
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i AW-97-1124
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(c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
l (d).
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive
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advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving I
Westinghouse of a competitive advantage.
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(e)
Unrestric;ed disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the '
l competition of those countries.
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' (f)
The Westinghouse capacity to invest corporate assets in research and p
development depends upon the success in obtaining and maintaining a
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6 competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method I
to the best of our knowledge and belief.
(v)
Enclosed is Letter NSD-NRC-97-5118, June 17,1997 being transmitted by Westinghouse Electric Corporation @ letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre @, to Mr. T. R. Quay, OtTice of NRR. The proprietary information as submitted for use by Westinghouse Electric Corporation is in response to questions concerning the AP600 plant and the associated design certification application and is expected to be L
applicable in other licensee submittals in response to certain NRC requirements for i
3188A u
r AW-97-1124
-o justification oflicensing advanced nuclear power plant designs.
This information is part of that which will enable Westinghouse to:
i (a)
Demonstrate the design and safety of the AP600 Passive Safety Systems.
(b)
Establish applicable verification testing methods.
J (c)
Design Advanced Nuclear Power Plants that meet NRC requirements.
i (d)
Establish technical and licensing approaches for the AP600 that will ultimately result in a certified design.
(e)
Assist customers in obtaining NRC approval for future plants.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar infonnation to its customers for 1:
i purposes of meeting NRC requirements for advanced plant licenses.
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(b)
Westinghouse can sell support and defense of the technology to its customers in the licensing process.
Public disclosure of this proprietary information,is likely to cause substantial harm to the competitive position of We tinghouse because it would enhance the ability of L
competitors to provide similar advanced nuclear power designs and licensing defense services for commercial power reactors without cornmensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information, t
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AW-97-1124 i
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The development of the technology described in part by the information is the result of l
applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of. Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
i Further the deponent sayeth not.
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i 3188A.
AP600 Fuel Leakage Assessment The fuel proposed for use in the AP600 is similar to the Westinghouse 17 x 17 Vantage 5 Hybrid (V5H) design (0.374" diameter fuel rod). There will be 38,280 power producing rods in 145 assemblies which produce a nominal power of 1933 MWt. The V5H type of fuel has been installed in many of the currently operating plants and is performing well. The significant differences between the AP600 fuel and the V5H fuel is described in SSAR Section 4.1.
Operating Plant Reactor Coolant Activity The following table presents the operating plant coolant activity report for those plants currently using this type of fuel. This dcta includes only nuclides of lodine.
January 1997 Operating Plant Coolant Activity for Plants With 17VSH Fuel Plant Sample Letdown L131 L131/
L134 h, c, W 1
6/19/96 100 2
12/19/96 100 3
11/24/96 100 4
3/17/96 100 5
11/24/96 94 6
11/24/96 100 7
12/26/96 100 8
9/11/96 100 9
12/16/96 100 10 12/25/96 100 11 6/7/95 100 12 12/27/96 100
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The radionuclide I-131 concentration is less than 5E-04 for all cases. A comparison of the activity reports from these currently operating plants to the historical records of fuel leak incidents shows that the coolant activity will rise significantly if the defect rate approaches 0.25%
0628BAM.wPF#une 17.1997 3
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Westinghouse Fuel Leak History The history d seven incidents ot Westinghouse fuel leaks is summarized below. These incidents
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include the nighest coolant activities of four V5H fuel leak incidents and also for other types of fuel produced by Westinghouse; V5, Standard and V+.
Each incident record includes the available data for the concentrations of some radionuclides in the reactor coolant. Concentrations are in microCuries per cc.
The number of leaking fuel rods, the total nun.ber of rods in the core and the fraction of leaking 4
rods as a percentage is provided for each of these incidents. The means of determining the number of leaking fuel rods was through ultrasonic inspection, an accepted practice in the industry.
4 Summary - Highest Primary Coolant 1131 Activity Reported j
incident Leak L131 MicroCi/cc
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t Plant 7 l
Plant 7 Plant 11 i
Plant 11 Plant 9 Plant 14 Plant 14 t
The highest case coolant I-131 activities are more than twice the activities observed for the currently operating plants. The large (0.26%) leak fraction produced more than forty times the i
normal coolant activities. This incident occurred in a non-V5H type of fuel.' The worst fuel leak
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rate in V5H type fuel was 0.004%.
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0628BAM.wPF/ June 17, t997 4